Personal data processing policy

1. General terms

The current personal data processing policy is created in accordance with the Federal law requirements dated 07.27.2006 No. 152-FZ «On Personal Data» and defines the personal data processing sequence and personal data security arrangements, implemented by ELAN brow bar (hereinafter – the Operator).

1.1. The Operator sets as its overriding priority and condition for carrying out activities the observance of human and citizen's rights and freedoms if treated with personal data, including defence of rights for personal privacy, personal and family secret.
1.2. The current Operator's policy regarding the processing of personal data (hereinafter – the Policy) applies to all information that the Operator can obtain about the visitors of the website

2. Basic concepts used in the Policy

2.1. Automated processing of personal data – processing of personal data using computer technology;
2.2. Blocking of personal data – temporary termination of the processing of personal data (unless the processing is necessary to clarify personal data);
2.3. The website – a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at an IP address of;
2.4. Information system of personal data – a set of personal data contained in databases, and providing their processing by information technologies and technical means;
2.5. Depersonalization of personal data – actions as a result of which it would be impossible to determine, without using additional information, the ownership of personal data by a specific User or other subject of personal data;
2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
2.7. The Operator – a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data;
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website;
2.9. The User – any visitor of the website;
2.10. Provision of personal data – actions aimed at disclosing of personal data to a certain person or a certain group of persons;
2.11. Dissemination of personal data – any actions aimed at disclosing of personal data to general public (transfer of personal data) or at review of the personal data by the general public, including the disclosure of personal data in the media, posting on information and telecommunication networks or providing access to personal data in any other way;
2.12. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign individual or foreign legal entity;
2.13. Destruction of personal data – any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoring of the personal data content in the personal data information system, and/or physical carriers of personal data are destroyed.

3. The Operator can process the following personal data of the User

3.1. Surname, name, patronymic;
3.2. E-mail;
3.3. Phone numbers;
3.4. Also, the website collects and processes anonymized data about the visitors (including cookies) using Internet statistics services (Yandex. Metrica, Google Analytics and others).
3.5. The above listed data hereinafter in the text of the Policy are integrated in the common concept of Personal data.

4. Purposes of personal data processing

4.1. The purpose of the User's personal data processing is to inform the User by sending E-mails.
4.2. The Operator also has the right to send to the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending a letter to the Operator's E-mail address with the note «Refusal of notifications about new products and services and special offers».
4.3. Anonymized Users' data collected using Internet statistics services are used to collect information about the Users' actions on the website, improve the quality of the website and its content.

5. Legal basis for the processing of personal data

5.1. The Operator processes the User's personal data only if it is filled in and/or sent by the User by himself/herself through special forms located on the website By filling out the respective forms and/or sending his/her personal data to the Operator, the User agrees with this Policy.
5.2. The Operator processes anonymized data about the User if it is allowed in the settings of the User's browser (the storage of cookies and the use of JavaScript technology are enabled).

6. The procedure for collecting, storing, transferring and other types of processing of personal data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the domain of personal data protection.

6.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.
6.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of the current legislation.
6.3. In case of inaccuracies discovery in the personal data, the User can update them independently by sending a notification to the Operator's E-mail marked «Updating personal data».
6.4. The period for personal data processing is unlimited. The User can at any time revoke his/her consent to the processing of personal data by sending a notification to the Operator's E-mail marked "Withdrawal of consent to the processing of personal data".

7. Cross-border transfer of personal data

7.1. Before starting the cross-border transfer of personal data, the operator is obliged to make sure that the foreign state to whose territory it is supposed to transfer personal data provides reliable protection of the rights of subjects of personal data.
7.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above mentioned requirements can be carried out only if the subject of personal data has a written consent to the cross-border transfer of his/her personal data and/or the performance of a contract where the subject of personal data is a party.

8. Final provisions

8.1. The User can receive any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via E-mail
8.2. This document will reflect any changes in the personal data processing policy by the Operator. The policy is valid indefinitely until it is replaced by an updated version.
8.3. The relevant version of the Policy is freely available on the Internet at

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